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Paul Boller helps clients navigate a variety of federal and state statutory and regulatory requirements in consumer financial services.

Like most industries today, consumer finance services businesses are being significantly impacted by the novel coronavirus (“COVID-19”). Troutman Sanders and Pepper Hamilton have developed a dedicated COVID-19 Resource Center to guide clients through this unprecedented global health challenge. We regularly update this site with COVID-19-related news and developments, recommendations from leading health organizations, and tools

Like most industries today, Consumer Financial Services businesses are being significantly impacted by the novel coronavirus (COVID-19). Troutman Sanders and Pepper Hamilton have developed a dedicated COVID-19 Resource Center to guide clients through this unprecedented global health challenge. We regularly update this site with COVID-19 news and developments, recommendations from leading health organizations, and tools

On February 26, the Consumer Financial Protection Bureau added ten FAQs concerning lender credits to its TILA-RESPA Integrated Disclosures (“TRID”) FAQs resource.

The new lender credit FAQs appear to be consistent with the industry’s current practices for managing and disclosing lender credits. They address topics such as:

  • How to define a lender credit for

On January 29, the U.S. House of Representatives passed the Comprehensive Credit Act (“the Act”). Packaging several Democrat-sponsored bills together, the Act garnered the support of all but two of the present House Democrats. If enacted into law, the Act would significantly change the information that credit reports can contain, expand the processes available

On December 19, New York Gov. Andrew Cuomo announced his intent to advance a legislative proposal to license debt collectors operating within the state. Announced as the 8th proposal of the 2020 State of the State agenda, it “would give the state new tools to regulate debt collectors – stopping unscrupulous practices and strengthening our

On November 25, the Consumer Financial Protection Bureau announced settlements with a military travel lender, its principal, and the servicer of its loans. The now defunct Edmiston Marketing, LLC, operating under the name of Easy Military Travel, provided financing to military servicemembers and their families for the purchasing of airline tickets. The CFPB determined that

The California Department of Business Oversight (“DBO”) on October 25 published a regulatory proposal to “modernize” the California Financing Law (“CFL”) licensing process. To do so, the DBO proposed amending existing licensing rules to transition all licensees onto the Nationwide Multistate Licensing System (“NMLS”). According to the notice of rulemaking, today many CFL licensees

On September 25, California Assembly Bill 539 was presented to the Governor for signing. The Bill would prohibit licensees of the California Financing Law (CFL) from charging an interest rate greater than 36% plus the applicable Federal Funds Rate on consumer loans of at least $2,500, but less than $10,000. Currently the CFL does not

Rhode Island has amended its electronic money transfer law to require state licensing for certain entities providing cryptocurrency or “virtual currency”-related services. Specifically, entities that maintain “control of virtual currency or transactions in virtual currency on behalf of others” will need to become “currency transmission” licensees. An entity controls virtual currency if it has “the

On July 25, the Consumer Financial Protection Bureau released an Advance Notice of Proposed Rulemaking (“ANPR”) asking for the mortgage industry’s opinion on the scheduled expiration of a provision in its Ability to Repay/Qualified Mortgage Rule (“Rule”), commonly known as the “QM patch.” The QM patch allows certain mortgage loans that are eligible for purchase